Episode 3: How to be MTD ready

Steve Cox 00:06 

Welcome to ACCOUNTED FOR, the IRIS interviews Podcast. I’m Steve Cox, Head of Market Insights at IRIS Software Group. I’ve been working in the accountancy industry for almost 20 years now and I’ve been working alongside our guest today for just as long. And today’s topic is all around Making Tax Digital, and specifically around how people can get ready for it. It’s already here, which a lot of people have now become part of business as usual. But what’s really interesting is the next evolution the next step of MTD, and how accountancy firms can really prepare themselves and their clients for it. But I couldn’t do it alone. So, joining me today is Jenny Strudwick. Jenny, do you want to introduce yourself for a bit around you, about what you do at IRIS as well, please? 

Jenny Strudwick 00:51 

Thanks, Steve. Yep, my name is Jenny Strudwick. I am the Tax Product Director at IRIS. I’ve worked in the sort of accountancy industry for about 23 years, I’ve been at IRIS for nearly 20 years, always worked within the tax divisions. And I’ve spent quite a lot of time over the last few years working very closely with HMRC, on big changes around legislation. And obviously, at the moment that is making tax digital. 

Steve Cox 01:19 

Must see quite a lot of change over that period, then specifically, with HMRC. They change obviously, roles quite frequently, but it kind of feels like their strategy has always been on this digital front. 

Jenny Strudwick 01:29 

Yeah, we have seen we have seen a lot of change. I mean, I think the sort of the most biggest thing before making tax digital was probably all-around AI experimental, that was quite a big change. In comparison to that this is much, much bigger, in terms of the way accountants have to work and the data that’s being submitted or at least the way that data is submitted. So yeah, it is a much, much bigger change than we’ve seen for quite some time. 

Steve Cox 01:54 

Well, MTD, for VAT has, I’m going to say been and gone because it is part of business as usual now for most firms, but the big thing that’s on everybody’s kind of lips at the moment is making tax digital for income tax. And from a lot of the firms that I speak to, we can explore that in a minute, but a lot of them are still thinking that it’s not going to happen. What’s your view? Is it going to happen or not? 

Jenny Strudwick 02:17 

Yeah, I can understand why you still hear that I still hear that from a lot of accountancy practices, I think there are some that are either believing or hoping that MTD will disappear. I think it stems from the fact that we’ve seen a fair amount of change of switching of priorities and some delays along the way. The fact that we’ve now got it legislated for me means that it’s not it’s not going to disappear. You know, there’s always the chance of there being further changes, or changing priorities and exactly how it’s applied. But it’s going to happen now there’s no way it’s just going to disappear. 

Steve Cox 02:53 

So, let’s just dig into a little bit around kind of what making tax digital for income tax is really about. So, with the VAT bit it was all aligned to the VAT quarters, this isn’t our income tax, right, so completely different kettle of fish. So, what are the kind of the fundamentals that will change as a part of MTD. 

Jenny Strudwick 03:12 

So, it only affects taxpayers that have got self-employment and or land or property income. And it’s those pieces of their income that need to be submitted more frequently to HMRC. I think the biggest thing for people to try and remember is that the data that’s being submitted to HMRC isn’t changing, it’s the same data that everyone currently puts on their tax return. So, when it comes to self-employment income, the data that goes on the SA 103 pages of their tax return is what’s being submitted to HMRC under MTD, it just needs to be submitted on a quarterly basis. The real difference, I guess, is other than the fact that they’re having to make quarterly submissions as opposed to just one, the real difference is the whole concept of digital record keeping. So it’s this requirement that data has to be recorded much closer to real time. And it has to be stored in a single place. And you know, the transfer of that data to HMRC has to happen via software. It doesn’t have to be one single piece of software, there could be multiple solutions used in the process. But the transfer of that data has to be digital between each piece of software. So you can’t rekey information anywhere along the process. And I think that’s probably the biggest change. 

Steve Cox 04:23 

And it’s probably an important point just to make sure that the listeners are understood that it’s no net new data, right? It’s just the same information but just quarterly, right? So, you’re not giving the government any additional information, just of more frequency. So ultimately, they can kind of make sure that the tax liability is going to be aware of by the time we get to the year end for it. But importantly, that this is something that accountants, in theory should already have processes for really, they do a lot of quarterly work with VAT. So, this is just a different client set. So is it a big change do you think within firms to change that mindset for the quarterly submissions, or is the real big bit like you were saying it’s around getting the digital records bit, is that where the problem is and the major challenge? 

Jenny Strudwick 05:09 

I think it’s probably a little bit of both. So because with VAT, you’re talking about businesses predominantly with a turnover above the VAT threshold, obviously, there’ll be some that are in VAT that that don’t have a turnover that high. But the majority of them have that turnover above the VAT threshold. Whereas for income tax, we’re talking about individuals with turnover of 10,000 pounds a year or more. So, you’re talking much, much smaller businesses, or individuals that just rent out a bit of property, they don’t really even see it as a business. So, for those types of clients, they don’t, they’ve never probably even thought about maintaining records in the way that you know, MTD kind of requires. So I think that’s probably where they’re seeing the biggest change is trying to get their clients to act in a different way, or take on a bit more a bit more responsibility in terms of the record keeping. 

Steve Cox 05:57 

And we probably all know those clients that everything’s still paper based, right? You think of those manual trades, and crikey we’ve had builders in recently, and his filing system was his glove box. And all of his receipts were in there. Right? So we’ve all got those kinds of clients. So do we think that the biggest challenge for accountants right now is how to change the mindset of their clients from the way they’ve always done things with paper-based records to now suddenly go, yeah, we’ve got to keep them digitally? Or is there an alternative option that they can kind of go down? That means, Joe, the plumber can keep his filing cabinet in his glove box, but actually, the accounting just does a bit more of the digital work for them? 

Jenny Strudwick 06:34 

Yeah, absolutely. And I think this is this is kind of the thing that we’re trying to educate more of our customer base on is that they’ve got options. So we talk a lot about digital record keeping, I believe the assumption is that that means a digital bookkeeping solution. And it doesn’t really I mean, that is a really good way to maintain digital records. But there are options. So when you’re talking about those clients that are really difficult, that don’t want to do their own bookkeeping, they don’t want, you know, bookkeeping package to update themselves, you don’t have to force them down that route. So as an accountant, like I say, you’ve got options, spreadsheets are still an option might not be the most efficient option. But it is still an option that’s available to those clients that can’t move or don’t want to move to anything else. There are also receipt capture apps. So you know, it might be much easier to get a client to just take pictures of invoices and receipts. And then you as the accountant can do the bookkeeping part based on those images. So there are lots of different options. It’s not about putting every single client into a bookkeeping package.  

Steve Cox 07:36 

I think a lot of firms are seeing it as, I’ve got this volume of clients, I’ve got to go with MTD, maybe they’re thinking is this big step change for them, from what you’ve just said, there is actually, they might not need to make the big change for the clients, they might just need to make a change in their process for how they get their data in. And I mean, I talk to accountancy firms all the time and one firm, they describe that receipt capture bit as probably the most important part of their process, because the way they say it is it’s not just about receipt capture, actually, they use that as their whole records, kind of keeping piece that if the data comes in digitally, so they’re taking a photo of a receipt, and it’s doing all the OCR piece to automatically put it into the bookkeeper. But they don’t need to go into the bookkeeping solution, because it’s automatically been recognised, all they’re doing is, when it comes to if they doing monthly accounts, or whether they’re doing the quarterly filings, they’re just pulling that data in electronically, like you’re saying no human intervention. So actually, once they’ve done that initial bit of hard work of changing the process, the efficiency seems to be flowing through for the rest of the chain almost. So, in some regards, and this is me now speculating if HMRC ever decided to go from quarterly to bi-monthly or to monthly, that process would still work, right? It wouldn’t be something they’d need to fundamentally rewrite again, it would just be something they can just change the frequency on. 

Jenny Strudwick 08:56 

Yeah, I mean, I can’t see that happening. But in theory, yeah, I think if that work is done upfront, like you say, just to improve processes and get things automated, then yeah, it doesn’t really matter how frequent the data is submitted. 

Steve Cox 09:11 

And I think the problem for accountants and so the voice that I’ve heard is very much that with clients trying to break their old habits, we know it’s really easy as individuals to fall into bad habits. It’s even harder though to break those habits. So I suppose that’s what accountants have got to do and not so much a case of just going to them now with that right you owe X amount of tax or here’s your final accounts. Now, it’s almost like you’re doing a bit of coaching with them, isn’t it is this is now how you’ve got to work because this will help you further down the line so that breaking a bad habit is probably one of the biggest areas accountants might be struggling with right now. But, something that is always on the mind of accountants is deadlines, right. So we said already the volume is going up so the frequency of how many times I’ve got to go and do this. We have historically for years, is always gone on about the busy period being kind of end of November through to January, for some it’s into February. But that busy period, does that now mean that’s gonna happen four times a year? 

Jenny Strudwick 10:16 

Not exactly. So the 31st of January deadline is still going to exist, you’re still going to end up with that busy period. Because, you know, whether you call it an end of year submission, or a final declaration, ultimately, everything else that goes on your tax return, that still has the same, that same deadline, that’s still going to exist, what you’ve got, in addition to that now is four quarters throughout the tax year, where your clients trading and or land or property income also need to be submitted. So from an accountant’s perspective, absolutely, that’s going to be probably the biggest thing to try and track and monitor, is you’ve got those different submission dates. Now across the year, you’ll have it applied to some clients, but not all clients, depending on the types of income they’ve got. And how clients are handled within the practice will vary what an accountant does, around those dates. So if you’ve got clients that are making their own submissions, you might treat them very differently in terms of a client that you’re making submissions for, on behalf of. So you’ll be going to be prompting some clients to say your submission is due you need to take action. And some clients where you’re going to be saying I’m going to make your submission for you, the whole idea of tracking and monitoring the status of all your different clients, all these different points in the year is going to become slightly more complicated, I think. And so that’s why it’s really important to be able to track and monitor exactly what’s going on for every client. 

Steve Cox 11:37 

And that kind of monitoring almost like setting the right expectations to the client seems critical. And I was only with a firm two weeks ago, and we were talking exactly about MTD, they seem to be massively prepared for this, which I’ve got to be honest, was a bit of a breath of fresh air from some of the firms I’ve seen. But what they were doing is they’ve changed the way that they actually do the whole pricing and packaging. So they now when it comes to bookkeeping, they could just call it the kind of the standard for them is they have an unmanaged setup, where the client manages their own books, and all they’re doing is providing the information to the accountant, probably on paper or via another method, quarterly. You’ve then got the part managed, which is the accountants got access to their systems, and they’re just pulling the data in as and when it’s needed to check it. But ultimately, they’re doing that for the year end, then you’ve got the fully managed, where they’re doing absolutely everything. And therefore, they’re doing all the submissions for them. And it was quite this breath of fresh air to see that they had almost like cohorts of these clients so that they knew what expectations were, what they were paying for. But actually, they also saw it as an opportunity to say, well, those aren’t managed, we can upsell to a part-managed. And those partners we can upsell to a fully-managed. So it kind of feels like if you get things correct and sorted, there’s a big opportunity there right with the clients for upsell, as well as to just ease the burden for them, surely. 

Jenny Strudwick  13:02 

Completely, for me that that step of organising your client base and putting them into a category is kind of like the ultimate first step for MTD. I’ve said it a number of times for me that is the key piece that needs to happen, not just so that a practice, like that one you just described can determine what services they can provide, because that’s a key part of it. And knowing what they can upsell is going to be really, really key in terms of working out what the accountant’s processes are, how they’re going to handle their workload, what team members they need in place who’s going to do what roles going forward. For me, everything spins off of that one task, and it’s one that’s really, really critical and needs to be done as soon as possible. Because April ‘24 sounds like a long way away, but if there’s all these things that need to be organised, prior to that date, it’s something that needs to happen sooner rather than later I think. 

Steve Cox 13:54 

The April 2024 date is an interesting one. Because most people go, we’re not even into 2023 yet. So why do I need to bother with 2024? But the preparation that you mentioned is really key and I was reading a stat recently in an external survey, which was all about how one in five SMEs still have never heard of MTD. Now, my gut feel tells me that a lot of those are non VAT registered, because actually, if they’re VAT registered, they should know of MTD, right, and their accountant should have told them about it. But if one in five still don’t know, surely this has got to be all about communication. 

Jenny Strudwick 14:32 

100% communication is really, really key to this and it’s something that we talk to HMRC about quite a lot. Because, you know as important as it is for us in the industry to talk about MTD, it really needs to start with HMRC and with the government direct so we do talk to them quite a lot about that. But I completely agree. I think the vast majority of SMEs out there don’t know what MTD is, I think even to your point about if they’re VAT registered, they should. I’m not even sure they would necessarily because MTD for VAT wasn’t a major change, you know, it was still quarterly filing, a lot of them probably would have been swept into the process without really realising that they were doing anything different. 

Steve Cox 15:10 

Especially if they’re being fully managed by the accountant right, they wouldn’t know what’s going on, it’s just, I’m giving the data and my accountant is sorting it for me, right? 

Jenny Strudwick 15:16 

Exactly. And those that do recognise that they’ve moved into making tax digital, when they hear further talk of it might not even acknowledge the fact that this is something different that we’re now talking about MTD, for income tax, you know, in their minds, they could be thinking, Oh, I’ve already done that, I’ve ticked that box. So there does need to be a whole lot more education and communication around it. 

Steve Cox 15:36 

So it kind of feels like a key takeaway for the listeners that one of the big things they should be doing right now is communicating to their clients, and ultimately communicating to their staff around the resources and the processes, they’re going to go down for this, that might set them on the right path to being prepared for this. So let’s just move forwards a little bit onto kind of the the MTD bit you mentioned around the whole legislation piece. Now, there was a big piece on Accounting Web all around how the three line accounts have now been legislated. It was the top topic on Accounting Web for a week huge kind of discussion topic. What did you take away from it, though? 

Jenny Strudwick 16:13 

To be honest, I was really surprised by the reaction to the announcement for me, it wasn’t, it wasn’t as big as it was portrayed on the media. So when I saw that the legislation had been made to me, it was really expected, it was kind of what we were expecting to see. It’s no different to what our current processes are. So that, you know, the legislation said that for self employed people with turnover beneath that, beneath the VAT threshold, they could choose whether or not to submit all their different income and expense types or whether they just submit two figures, the total income and the total expenses. That’s exactly what we have now today with your tax return. So it didn’t surprise me at all. Probably reactions to it surprise me slightly more. My biggest takeaway from that announcement, though, is that, you know, as good as it is to have these things put down in legislation, we’re still missing the detail around it. So there are big questions for me as to what this actually means or how you put this into action. So to give an example, with that particular piece of information, if a sole trader chooses to just submit two figures, just my total income, my total expenses, because you know, my turnover is beneath the VAT threshold. And they do that for the first three quarters. And then they get to their fourth quarter, suddenly, their turnover goes above the VAT threshold. What do they do in that scenario? Do they then submit four details for their final quarter, which then doesn’t match their previous three quarters? Or do they resubmit the previous three quarters? It’s, it’s that sort of information that we’re kind of lacking when those sorts of announcements are made. And until you get that information, you don’t really know what the announcement means do you know what I mean, so I feel like there’s just, there’s just still a lot more information that is provided. 

Steve Cox 17:57 

And often when we talk about HMRC, and the whole kind of like digital by default into making tax digital, it’s often seen as people are always saying, well, I still want to know more, I want to know more, it must be quite hard for HMRC. Because it’s a bit like the swan, right? Looks elegant on top. Most people probably laugh at me comparing HMRC to a swan. But underneath, there’s a load paddling going on, they must be doing a hell of a lot in the background to try and get this ready. And everyone’s still going no, I want more, I want more I need to know this information, quite rightly so because they need to then educate their clients and talk through it. So what’s your experience of kind of working with HMRC? On these side of things? 

Jenny Strudwick 18:35 

It is exactly that is exactly how you’ve described it. So, you know, as critical as I might be that I need, I need that extra detail that is the way it is with everything. And like you say there are so many different things going on at the moment, so many different points and aspects that are being worked out and analysed that they sometimes have to put that data out there before they’ve got all the detail otherwise, you know, you’re waiting even longer for any information. So absolutely they are they are putting pieces of information out there. There is an awful lot going on. It’s not like it’s just not even thought about. There is a lot of analysis that’s going on at the same time. So I know, you know, I don’t have any doubt that the detail will follow. It’s just sometimes it takes a little bit longer than you’d hoped. 

Steve Cox 19:16 

So we’re in the MTD for it’s a pilot right now that that period. Now, a lot of people have criticised the pilot, and you can go and read all about it on the various accounting websites. But for me, what’s been really interesting is it when you speak to firms and you say, right, are you gonna go jump into the pilot? And they’re like, well, actually, we’ve spoken to some clients and we thought 30 of them might have joined us actually turned out, only five are interested. And then those five when they’ve tried to go through, they don’t meet the criteria. So actually, it’s only been one, so potentially 30 down to one have been able to join the pilot. And I suppose in some regards that kind of what a pilot is right, going for what the simplest case is to get that right and then expand the criteria. So are we starting to see in the pilot, the criteria expanding, and therefore we’ll see more people going into it? 

Jenny Strudwick 20:04 

So we’re not seeing it expand just yet. But it’s coming very soon from what HMRC tell us, it’s going to start to expand over the next sort of this month or next month. Because you’re absolutely right, you know, the participation numbers do seem to be very, very low. But it is, from what we hear intentional, HMRC want to keep it very, very controlled. The last thing they want to do is have loads of people jump into the pilot, and have a bad experience, that’s ultimately not going to help anyone. So they are keeping it very, very controlled, keeping it very small numbers, like you said, just to get through the very simplest of scenarios before then opening up to more and more taxpayers. So yeah, hopefully, from what we’ve heard, it should be this month or next month that we start to see it open a bit wider on the criteria. 

Steve Cox 20:48 

So before it opens up to wider, what’s the criteria and qualifications to get into the pilot at the moment, because they’re quite restrictive, right? 

Jenny Strudwick 20:55 

They are very restricted. In terms of the the individual has to have either a single self-employment, and all land and property income, obviously, otherwise, there’s no point in being in the pilot. But in terms of other income that they can have alongside that, they can’t have anything else. But I think the biggest restriction that we’re seeing that most people struggle with at the moment is that their accounting period has to be exactly aligned to the tax year. So anyone that deviates from that even slightly, you know, there are lots of businesses at the moment they use 31st of March as if it was the 5th of April, because they’re treated as the same thing at the moment. In MTD, they can’t be it has to align exactly to the tax year. So that seems to be the biggest stumbling block at the moment for people that want to join, but not able to just yet. 

Steve Cox 21:41 

And to join, they have to get on a specific route, right, they can’t go and sign up on their own, the clients can’t go sign up for a pilot, they’ve got to go through their software vendors that come to like IRIS and people like that. Obviously, you’re dealing with a lot of that at the moment with our own customers that are coming through our products, we want to sign up, is that a smooth process for them to sign up? Is it a lot of work for you, or IRIS as a vendor to go and do? 

Jenny Strudwick 22:04 

It really varies based on the outcome of the eligibility check. So you’re quite right. If an agent wants to put a client into the pilot, they need to speak to their software vendor. And then the software vendor speaks to HMRC. So you have to pass along information, we’re kind of like an in between, we pass along information so that HMRC can carry out the checks and the results of those checks, come back to us the software vendor, and then we talk to the client. If everything goes smoothly, it can be quite an easy transition, quite an easy process, it can be a little bit time consuming depending on how busy the different departments are. So it might take a few weeks to get from one end to the other. The problems occur when the checks are not met. So the client isn’t eligible to join, HMRC can’t tell the software vendor why because we are not, we’re not privy to that information, data protection, etc. So obviously, we have to relay that information back to the accountant, the accountant can obviously contact HMRC directly and then find out why. But so those sorts of steps do put a little bit of a blocker in the process, I guess. 

Steve Cox 23:10 

And I can imagine that that’s probably a point of frustration for a lot of accountants because they spend time educating their client around MTD, what it is, why they need to be prepared, why now they should do rather than wait till April 2024. They’ve engaged with the software vendor, they’ve had to go to HMRC that like say could be weeks. By that point, they’re going back to the client and going oh, by the way, you’re now in the pilot, I can imagine that the client is going pilot what? I don’t remember because it’s not on their radar, right. It’s on the accountants radar. So it probably is a point of frustration. And maybe that will ease as the criteria and the eligibility opens up more. And let’s hope that that allows more accountants to then start putting more clients through. So let’s just think beyond the pilot now. So April 2024, we’re less than two years away. We’ve got more time now than we had in MTD for VAT because the pilot period was only a year so accountants have got more time to prepare for it. We said already that communication is critical internally and externally and around processes. But you touched on something that I just want to come back to which was all around the visibility and the management of it because a lot of people see MTD as a digital records or as a tax problem. But for me, it kind of feels more like a process problem and almost part of practice management than anything else. I mean, what’s your experience on this? 

Jenny Strudwick 24:34 

Absolutely. I think like you said at the beginning if a practice can get their processes in place, so they know how the data is coming in and they know who’s doing the submissions, that all becomes relatively straightforward. (Hopefully!) For me, the biggest task will be the practice management side of it. So like I said, the tracking whose submissions or what stage who’s due to make a submission, who’s made their submission all that sort of management of everything will become the bigger task, you know, yes, practice management software is the way that will make that much, much easier to manage and maintain going forward. Because when I talk about multiple submissions in a year, we’ve already said, you know, you’ve got your four quarters for self-employment. There’s more than that. So you have an end of period statements, there’s actually five submissions. We’ve got the final declaration, which is kind of like the tax return equivalent for that client, if they’ve got land or property income as well, there’s four submissions with that if they’ve got different types of land or property. So if they’ve got, I don’t know, a property in the UK and a property abroad, there are actually different submissions. So do you know what I mean, the number of submissions start to mount up. 

Steve Cox 25:40 

So, it’s not only a case of managing those various submissions and deadlines for each of those like you said, rather than just four, it could be a lot more. But I suppose the other side of things is because there’s that many more things, you’re potentially going to need a bigger workforce, more staff to go and do this. If we take that through and think about well, actually, yes, they’re still going to be the busy period at the end of January, does that mean we’re going to have mini busy periods at the end of each quarter now? So do you need more temporary staff at that point? Do you need to be more flexible with it? These are probably all things that accountants might not be thinking about now. So maybe another piece of advice as a takeaway for them could be that have a look at the staff you’ve got today, have they one, got the right skills in place to be able to do this because as we said, it’s around coaching now not so much around the technicals of tax, two is then have you got the right number of staff to go and do this to account for some of these kind of peaks and troughs for it. And I suppose the third bit then is really around that, have you got the right tracking in place the practice management piece to be able to cater for all of this additional deadlines, that is going to be so critical to get right. Because if that’s wrong at the volumes most accountants deal with that potentially in the future could mean penalties. Right now we’re in a soft-landing period. So we don’t have to worry so much about that. But that could be a problem for them. So just before we kind of finish this podcast, the one of the things I kind of wanted to ask you is, other than the bits we’ve just talked about, what’s the one thing that you would say to an accountant who’s thinking MTD, what do I do? How do I prepare? If you had to give them one piece of advice? What would you give them? 

Jenny Strudwick 27:24 

It’s preparation. So this encompasses a number of things, I guess. But for me, you can’t be too prepared for this. And like I say, starting nice and early will be the way to do that. There’s lots of information out there. We as software developers are more than happy for our customer base to come and talk to us come and look at the content we’ve got available. We’re trying to put more and more out all the time to help not only the accountant with their own education, but the education of their clients. So there is lots of data out there, I’d say go and look and find out what you can reach out to people reach out to your software provider and start that preparation and planning that, you know working out how where your clients sit in the different categories, how you’re going to help them what services you’re going to provide. All that sort of preparation will be the key. The key way to succeed with MTD. 

Steve Cox 28:12 

Brilliant, Jenny, absolute pleasure. Thank you very much. Hopefully our listeners have taken away quite a few different points on this from today. But if you’ve got any suggestions of areas that you want us to go and explore, maybe it’s more in depth on one particular area of MTD or it might be a different topic that you want to explore. Let us know because we’ll explore these as we go through the ACCOUNTED FOR podcast and we’ll bring specialists in and experts to cover each of those topics. But a final thank you from me, to say thank you for listening and make sure you subscribe to our channel and follow us on social media. And until then, I’ll speak to you soon.